The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Scott Sullivan, the Chief Integrity and Compliance Officer at Newmont Mining.
Scott Sullivan is a versatile and innovative governance, risk, compliance, ethics and legal executive with significant experience advising C-suite leaders and Boards of Directors in a global enterprise in a wide array of sensitive, high profile subject matter areas. He has extensive leadership in designing, implementing and enhancing world-class programs and favorably resolving regulatory crises for multinationals. He has managed ethics and compliance for a $5B global Fortune 500 corporation, directing a Business Integrity & Compliance function impacting 20,000 employees in over 55 countries with over 100 legal entities.
In this final episode, Sullivan discusses how the role of a CCO has evolved from a legal response to government enforcement under the FCPA; driven by lawyers to something else. We consider some of some of the biggest changes for Sullivan has observed. We conclude by looking down the road, as we move into the 2020s where Sullivan sees compliance moving to? It includes data, data, data – continuous monitoring, automation, finely tuned machine and how some of the changes wrought by Covid-19 accelerate these trends and perhaps others; including remote options, less travel and opportunities outside traditional comfort zone for compliance professionals.
Tag: CCO
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Scott Sullivan, the Chief Integrity and Compliance Officer at Newmont Mining.
Scott Sullivan is a versatile and innovative governance, risk, compliance, ethics and legal executive with significant experience advising C-suite leaders and Boards of Directors in a global enterprise in a wide array of sensitive, high profile subject matter areas. He has extensive leadership in designing, implementing and enhancing world-class programs and favorably resolving regulatory crises for multinationals. He has managed ethics and compliance for a $5B global Fortune 500 corporation, directing a Business Integrity & Compliance function impacting 20,000 employees in over 55 countries with over 100 legal entities.
In this Episode 3, we consider how a CCO can complement their own skills with their team. Some of the skills sets Sullivan sees needed for 2020 and beyond include, Project Management, data analytics, communications & marketing, plus legal. Sullivan lists his 4 top leadership lessons for leading a compliance team.
- People First – Empower Them to Lead.
- Roll up your sleeves – don’t be afraid to dive in.
- Manage the Chaos to Thrive not just Survive.
- Trust your gut and instincts – judgmental vs. statistical sampling.
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Ryan Rabalais, currently an Ethics and Compliance Officer at Bechtel Oil, Gas & Chemicals. Rabalais has been Vice President and CCO at both Rowan Companies and Paragon Offshore.
Ryan Rabalais has over two decades of legal and compliance experience in the oil and gas sector, including being a Vice President & Chief Compliance Officer for two different companies with global operations. Ryan has a history of providing practical solutions to the business and managing overall corporate and regulatory compliance programs. His compliance experience includes a particular focus on anti-corruption, sanctions, trade controls and US anti-boycott, with reporting responsibilities to senior management and the Board of Directors of large, publicly traded companies.
In this final episode, Ryan talks about the all-important role of culture in an organization and the role of the CCO in being a spokesman for culture. He concludes with some thoughts about the importance of institutional justice and institutional fairness and why the CCO needs to help lead this effort throughout the organization.
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Ryan Rabalais, currently an Ethics and Compliance Officer at Bechtel Oil, Gas & Chemicals. Rabalais has been Vice President and CCO at both Rowan Companies and Paragon Offshore.
Ryan Rabalais has over two decades of legal and compliance experience in the oil and gas sector, including being a Vice President & Chief Compliance Officer for two different companies with global operations. Ryan has a history of providing practical solutions to the business and managing overall corporate and regulatory compliance programs. His compliance experience includes a particular focus on anti-corruption, sanctions, trade controls and US anti-boycott, with reporting responsibilities to senior management and the Board of Directors of large, publicly traded companies.
In this Episode 3, Ryan relates some of the skill sets he has used in his journey to the CCO chair and while he has been in that position. They include being what Rabalais calls “Compliance wise” that is knowing the nuts and bolts of compliance and compliance programs so that you are a subject matter expert. You should also under how to do compliance; that is, how to design, create and implement a best practices compliance program. You should be able to communicate up and down the chain (here he brings the wisdom of a Marine. Finally, he ends with some thoughts on worldliness.
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Ryan Rabalais, currently an Ethics and Compliance Officer at Bechtel Oil, Gas & Chemicals. Rabalais has been Vice President and CCO at both Rowan Companies and Paragon Offshore.
Ryan Rabalais has over two decades of legal and compliance experience in the oil and gas sector, including being a Vice President & Chief Compliance Officer for two different companies with global operations. Ryan has a history of providing practical solutions to the business and managing overall corporate and regulatory compliance programs. His compliance experience includes a particular focus on anti-corruption, sanctions, trade controls and US anti-boycott, with reporting responsibilities to senior management and the Board of Directors of large, publicly traded companies.
In this Episode 2, we discuss the evolution of the compliance role from that of a legal solution written by lawyers for lawyers to the CCO being seen as a part of the business solution. It began with employees seeing the compliance function as The Land of No, populated by Dr. No to something very different today. We also consider the Black Box problem of compliance.
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. This month, I visit with Ellen Hunt, Senior Vice President – Audit, Ethics & Compliance Officer.
Ellen is a lawyer, ethics & compliance professional, and chief audit executive. She has extensive management experience in designing, implementing and operating ethics and compliance programs including board governance and reporting, designing ethics education, creating policy management frameworks, managing enterprise and compliance risk processes as well as handling investigations and regulatory inquiries. Utilizing AARP’s enterprise risk management profile, she re-designed how AARP conducts its annual audit planning process to identify audits that relate to the organization’s must significant risks and incorporated the use of data analytics into audit execution.
In this final episode, Ellen visits about what life can look like after you leave the CCO role. What are the types of corporate positions you are skilled for? As ethics and compliance matures, organizations are now seeing risks as positives. The question becomes how you are going to manage that risk for greater profitability; how you will strategically manage risk. We conclude with a discussion of why CCOs need to go onto Boards of Directors and why Boards need compliance expertise to navigate the post Covid-19 world.
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. This month, I visit with Ellen Hunt, Senior Vice President – Audit, Ethics & Compliance Officer.
Ellen is a lawyer, ethics & compliance professional, and chief audit executive. She has extensive management experience in designing, implementing and operating ethics and compliance programs including board governance and reporting, designing ethics education, creating policy management frameworks, managing enterprise and compliance risk processes as well as handling investigations and regulatory inquiries. Utilizing AARP’s enterprise risk management profile, she re-designed how AARP conducts its annual audit planning process to identify audits that relate to the organization’s must significant risks and incorporated the use of data analytics into audit execution.
In this episode, Ellen relates what happens when you get into the CCO chair. She emphasized it is a great opportunity. You must determine your highest risks and move to manage those risks. You need to get to know your team, assess their strengths and weakness and conclude how to use those skills. Learn the budgeting process and push for a realistic budget. Finally, get to know your Board and your Compliance Committee or Audit Committee chair.
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. This month, I visit with Ellen Hunt, Senior Vice President – Audit, Ethics & Compliance Officer. Ellen is a lawyer, ethics & compliance professional, and chief audit executive. She has extensive management experience in designing, implementing and operating ethics and compliance programs including board governance and reporting, designing ethics education, creating policy management frameworks, managing enterprise and compliance risk processes as well as handling investigations and regulatory inquiries. Utilizing AARP’s enterprise risk management profile, she re-designed how AARP conducts its annual audit planning process to identify audits that relate to the organization’s must significant risks and incorporated the use of data analytics into audit execution.
Ellen like many who are in compliance, came to it by (1) being drafted and (2) from the legal function. When she began, compliance was legalistic, rules-based; largely seen as an insurance policy in case there was a compliance failure. It has changed to a business process and every CCO needs to understand the business of their organization. We explore what skills you need to develop to grow in the compliance profession.
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recent mandate from the CDC that CEOs, CCOs and CFOs certify and attest that each employee who disembarks from a cruise ship has met the CDC requirements to do so, under potential criminal penalty. Three cruise lines, Royal Caribbean, Carnival Cruises, and Norwegian Cruise Line have over 100,000 employees cooped up on ships in US ports. The CDC wants to make certain that when they come on land, it is safe for everyone.
Some of the highlights include:
- What are the CDC requirements?
- Why does the CDC want CEO, CCO and CFO attestation?
- Should these corporate leaders agree to do so?
- What is about the employees on the ships?
- Given that at least 100 cruise ships that set sail after March 4, the first day that a passenger died of Covid-19 while on a cruise stopping in the United States, is this warranted?
- What does it mean for potential liability going forward?
Resources
Matt Kelly blog post, Cruise Lines Face Covid-19 Compliance Squeeze
The role of the CCO has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance, under Hallmark Three of the Ten Hallmarks of an Effective Compliance Program, it focused on the whether the CCO held senior management status and had a direct reporting line to the Board; stating:
In appraising a compliance program, DOJ and SEC also consider whether a company has assigned responsibility for the oversight and implementation of a company’s compliance program to one or more specific senior executives within an organization. Those individuals must have appropriate authority within the organization, adequate autonomy from management, and sufficient resources to ensure that the company’s compliance program is implemented effectively. Adequate autonomy generally includes direct access to an organization’s governing authority, such as the board of directors and committees of the board of directors.
This Hallmark was significantly expanded in both the 2019 Guidance and the FCPA Corporate Enforcement Policy. And in so doing, the DOJ has increased the prestige, authority and role of both the CCO and corporate compliance function. The 2019 Guidance has four general areas of inquiry around the CCO and corporate compliance function. (1) How does the CCO salary and stature within the organization compare to other senior executives within the company. (2) What are the experience and stature of the CCO with an organization? Does the CCO have appropriate training for the role? (3) How much autonomy does the CCO have to report to the Board of Directors? How often do the CCO meet with directors? Are members of the senior management present for these meetings with the Board of Directors or of the Audit Committee? (4) Is the compliance function run by a designated chief compliance officer, or another executive within the company, and does that person have other roles within the company?
Three key takeaways:
- How can you show the CCO really has a seat at the senior executive table?
- What are the professional qualifications of your CCO?
- Does your CCO have true independence to report directly to the Board of Directors?
